https://www.taxtmi.com/caselaws?id=245577 The Appellate Tribunal addressed two main issues in the appeal. Regarding the disallowance under section 36(1)(iii) for capital work-in-progress, the Tribunal gave the assessee another opportunity to prove its case before the assessing authority. Concerning the transfer pricing adjustment on international transactions, the Tribunal found no requirement for adjustment as the operating margin difference fell within the 5% safe harbor rule. The Tribunal held the sustenance of the adjustment directed by the Dispute Resolution Panel was not valid in law and ordered its deletion. The appeal was partly allowed on this issue for statistical purposes. en-us Mon, 20 Jan 2014 00:00:00 +0530 Wed, 02 Apr 2014 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245577 The Appellate Tribunal addressed two main issues in the appeal. Regarding the disallowance under section 36(1)(iii) for capital work-in-progress, the Tribunal gave the assessee another opportunity to prove its case before the assessing authority. Concerning the transfer pricing adjustment on international transactions, the Tribunal found no requirement for adjustment as the operating margin difference fell within the 5% safe harbor rule. The Tribunal held the sustenance of the adjustment directed by the Dispute Resolution Panel was not valid in law and ordered its deletion. The appeal was partly allowed on this issue for statistical purposes. Case-Laws Income Tax Mon, 20 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245577